Operating Personnel Communications Protocols Standard Audits... · Web viewA copy of the documented...

Reliability Standard Audit Worksheet1

COM-002-4 – Operating Personnel Communications Protocols

This section to be completed by the Compliance Enforcement Authority.

Audit ID: Audit ID if available; or REG-NCRnnnnn-YYYYMMDDRegistered Entity: Registered name of entity being auditedNCR Number: NCRnnnnn

Compliance Enforcement Authority:

Region or NERC performing audit

Compliance Assessment Date(s)2: Month DD, YYYY, to Month DD, YYYYCompliance Monitoring Method: [On-site Audit | Off-site Audit | Spot Check]Names of Auditors: Supplied by CEA

Applicability of RequirementsBA DP GO GOP IA LSE PA/PC PSE RC RP RSG TO TOP TP TSP

R1 X X XR2 X X XR3 X XR4 X X XR5 X X XR6 X X X XR7 X X X

Legend:Text with blue background: Fixed text – do not editText entry area with Green background: Entity-supplied information

1 NERC developed this Reliability Standard Audit Worksheet (RSAW) language in order to facilitate NERC’s and the Regional Entities’ assessment of a registered entity’s compliance with this Reliability Standard. The NERC RSAW language is written to specific versions of each NERC Reliability Standard. Entities using this RSAW should choose the version of the RSAW applicable to the Reliability Standard being assessed. While the information included in this RSAW provides some of the methodology that NERC has elected to use to assess compliance with the requirements of the Reliability Standard, this document should not be treated as a substitute for the Reliability Standard or viewed as additional Reliability Standard requirements. In all cases, the Regional Entity should rely on the language contained in the Reliability Standard itself, and not on the language contained in this RSAW, to determine compliance with the Reliability Standard. NERC’s Reliability Standards can be found on NERC’s website. Additionally, NERC Reliability Standards are updated frequently, and this RSAW may not necessarily be updated with the same frequency. Therefore, it is imperative that entities treat this RSAW as a reference document only, and not as a substitute or replacement for the Reliability Standard. It is the responsibility of the registered entity to verify its compliance with the latest approved version of the Reliability Standards, by the applicable governmental authority, relevant to its registration status.

The NERC RSAW language contained within this document provides a non-exclusive list, for informational purposes only, of examples of the types of evidence a registered entity may produce or may be asked to produce to demonstrate compliance with the Reliability Standard. A registered entity’s adherence to the examples contained within this RSAW does not necessarily constitute compliance with the applicable Reliability Standard, and NERC and the Regional Entity using this RSAW reserves the right to request additional evidence from the registered entity that is not included in this RSAW. Additionally, this RSAW includes excerpts from FERC Orders and other regulatory references. The FERC Order cites are provided for ease of reference only, and this document does not necessarily include all applicable Order provisions. In the event of a discrepancy between FERC Orders, and the language included in this document, FERC Orders shall prevail.

2 Compliance Assessment Date(s): The date(s) the actual compliance assessment (on-site audit, off-site spot check, etc.) occurs.

NERC Reliability Standard Audit Worksheet

Text entry area with white background: Auditor-supplied information

NERC Reliability Standard Audit Worksheet Audit ID: Audit ID if available; or NCRnnnnn-YYYYMMDDRSAW Version: RSAW_COM-002-4_2013_v3 Revision Date: February, 2016 RSAW Template: RSAW2014R1.2

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Findings(This section to be completed by the Compliance Enforcement Authority)

Req. Finding Summary and Documentation Functions MonitoredR1R2R3R4R5R6R7

Req. Areas of Concern

Req. Recommendations

Req. Positive Observations


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Subject Matter ExpertsIdentify the Subject Matter Expert(s) responsible for this Reliability Standard.

Registered Entity Response (Required; Insert additional rows if needed): SME Name Title Organization Requirement(s)


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R1 Supporting Evidence and Documentation

R1. Each Balancing Authority, Reliability Coordinator, and Transmission Operator shall develop documented communications protocols for its operating personnel that issue and receive Operating Instructions. The protocols shall, at a minimum:

1.1. Require its operating personnel that issue and receive an oral or written Operating Instruction to use the English language, unless agreed to otherwise. An alternate language may be used for internal operations.

1.2. Require its operating personnel that issue an oral two-party, person-to-person Operating Instruction to take one of the following actions:

Confirm the receiver’s response if the repeated information is correct.

Reissue the Operating Instruction if the repeated information is incorrect or if requested by the receiver.

Take an alternative action if a response is not received or if the Operating Instruction was not understood by the receiver.

1.3. Require its operating personnel that receive an oral two-party, person-to-person Operating Instruction to take one of the following actions:

Repeat, not necessarily verbatim, the Operating Instruction and receive confirmation from the issuer that the response was correct.

Request that the issuer reissue the Operating Instruction.

1.4. Require its operating personnel that issue a written or oral single-party to multiple-party burst Operating Instruction to confirm or verify that the Operating Instruction was received by at least one receiver of the Operating Instruction.

1.5. Specify the instances that require time identification when issuing an oral or written Operating Instruction and the format for that time identification.

1.6. Specify the nomenclature for Transmission interface Elements and Transmission interface Facilities when issuing an oral or written Operating Instruction.

M1. Each Balancing Authority, Reliability Coordinator, and Transmission Operator shall provide its documented communications protocols developed for Requirement R1.

Registered Entity Response (Required): Compliance Narrative:Provide a brief explanation, in your own words, of how you comply with this Requirement. References to supplied evidence, including links to the appropriate page, are recommended.


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Evidence Requestedi:Provide the following evidence, or other evidence to demonstrate compliance. A copy of the documented communication protocols that cover the Requirements outlined in Requirement R1 Parts 1.1 to 1.6.

Registered Entity Evidence (Required):The following information is requested for each document submitted as evidence. Also, evidence submitted should be highlighted and bookmarked, as appropriate, to identify the exact location where evidence of compliance may be found.

File Name Document Title

Revision or

VersionDocumen

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Relevant Page(s)

or Section(s)

Description of Applicability of Document

Audit Team Evidence Reviewed (This section to be completed by the Compliance Enforcement Authority):

Compliance Assessment Approach Specific to COM-002-4, R1This section to be completed by the Compliance Enforcement Authority

Review the documented communications protocols provided by the entity and ensure they address the Parts of R1 as follows:

(Part 1.1) Requires its operating personnel that issue and receive an oral or written Operating Instruction to use the English language, unless agreed to otherwise. An alternate language may be used for internal operations.(Part 1.2) Requires its operating personnel that issue an oral two-part, person-to-person Operating Instruction to take one of the following actions: confirm the receiver’s response if the repeated information is correct, reissue the Operating Instruction if the repeated information is incorrect or if requested by the receiver, or take an alternative action to issue a new or the same Operating Instruction if the receiver does not respond.(Part 1.3) Requires its operating personnel that receive an oral two-party, person-to-person Operating Instruction to take one of the following actions: repeat, not necessarily verbatim, the Operating Instruction and receive confirmation from the issuer that the response was correct, or request that the issuer reissue the Operating Instruction.(Part 1.4) Requires its operating personnel that issue a written or oral single-party to multiple-party burst Operating Instruction to confirm or verify that the Operating Instruction was received by at least one receiver of the Operating Instruction.(Part 1.5) Specifies the instances that require time identification when issuing an oral or written Operating Instruction and the format for that time identification.(Part 1.6) Specifies the nomenclature for Transmission interface Elements and Transmission interface


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Facilities when issuing an oral or written Operating Instruction.Note to Auditor:

Auditor Notes:


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R2. Each Balancing Authority, Reliability Coordinator, and Transmission Operator shall conduct initial training for each of its operating personnel responsible for the Real-time operation of the interconnected Bulk Electric System on the documented communications protocols developed in Requirement R1 prior to that individual operator issuing an Operating Instruction.

M2. Each Balancing Authority, Reliability Coordinator, and Transmission Operator shall provide its initial training records related to its documented communications protocols developed for Requirement R1 such as attendance logs, agendas, learning objectives, or course materials in fulfillment of Requirement R2.


Evidence Requestedi:Provide the following evidence, or other evidence to demonstrate compliance. Copies of dated attendance logs, agendas, learning objectives, or course materials as outlined in M2.Organization chart or similar artifact identifying the operating personnel responsible for the Real-time operation of the interconnected Bulk Electric System and the date such personnel became responsible for operating the Real-time Bulk Electric System.



Revision or

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Compliance Assessment Approach Specific to COM-002-4, R2NERC Reliability Standard Audit Worksheet Audit ID: Audit ID if available; or NCRnnnnn-YYYYMMDDRSAW Version: RSAW_COM-002-4_2013_v3 Revision Date: February, 2016 RSAW Template: RSAW2014R1.2

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This section to be completed by the Compliance Enforcement AuthorityReview the evidence provided and verify:

That all, or a sample of, the applicable operating personnel received the required training prior to issuing an Operating Instruction by matching selected personnel names to training records.

Note to Auditor:Requirement R2 requires only initial training; continuing training is not required.

Auditor Notes:


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R3. Each Distribution Provider and Generator Operator shall conduct initial training for each of its operating personnel who can receive an oral two-party, person-to-person Operating Instruction prior to that individual operator receiving an oral two-party, person-to-person Operating Instruction to either:

Repeat, not necessarily verbatim, the Operating Instruction and receive confirmation from the issuer that the response was correct, or


M3. Each Distribution Provider and Generator Operator shall provide its initial training records for its operating personnel such as attendance logs, agendas, learning objectives, or course materials in fulfillment of Requirement R3.


Evidence Requestedi:Provide the following evidence, or other evidence to demonstrate compliance. Copies of dated attendance logs, agendas, learning objectives, or course materials as outlined in M3.Organization chart or similar artifact identifying the operating personnel who can receive an oral two-party, person-to-person Operating Instruction and the date such personnel began receiving such instructions.



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Review the evidence provided and verify:That all, or a sample of, the applicable operating personnel received the required training prior to the date they began receiving oral two-party, person-to-person Operating Instructions by matching selected personnel names to training records.

Note to Auditor:Requirement R3 requires only initial training; continuing training is not required.

Auditor Notes:


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R4. Each Balancing Authority, Reliability Coordinator, and Transmission Operator shall, at least once every twelve (12) calendar months:

4.1. Assess adherence to the documented communications protocols in Requirement R1 by its operating personnel that issue and receive Operating Instructions, provide feedback to those operating personnel and take corrective action, as deemed appropriate by the entity, to address deviations from the documented protocols.

4.2. Assess the effectiveness of its documented communications protocols in Requirement R1 for its operating personnel that issue and receive Operating Instructions and modify its documented communication protocols, as necessary.

M4. Each Balancing Authority, Reliability Coordinator, and Transmission Operator shall provide evidence of its assessments, including spreadsheets, logs or other evidence of feedback, findings of effectiveness and any changes made to its documented communications protocols developed for Requirement R1 in fulfillment of Requirement R4. The entity shall provide, as part of its assessment, evidence of any corrective actions taken where an operating personnel’s non-adherence to the protocols developed in Requirement R1 is the sole or partial cause of an Emergency and for all other instances where the entity determined that it was appropriate to take a corrective action to address deviations from the documented protocols developed in Requirement R1.

Registered Entity Response (Required): Question: Did the entity have any Emergencies on its system due to non-adherence to documented communication protocols during the compliance monitoring period? ☐ Yes ☐ No[If Yes, provide a list of such Emergencies including any corrective actions taken in response to the Emergencies and proceed to the Compliance Narrative section below. If No, proceed to the Compliance Narrative section below.][Note: A separate spreadsheet or other document may be used. If so, provide the document reference below.]


Evidence Requestedi:Provide the following evidence, or other evidence to demonstrate compliance. Dated spreadsheets, logs, or other evidence of assessment of adherence to the documented communication protocols and feedback to operating personnel as outlined in M4.Assessments, minutes of meetings or others summaries evidencing an assessment of the effectiveness of


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documented protocols and any corresponding revisions made to documented communications protocols.A list or log of corrective actions taken in response to Emergencies occurring on the entity’s system due to non-adherence to documented communications protocols during the audit period.



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Review the evidence provided and verify:(Part 4.1) That an assessment of operating personnel issuing and receiving Operating Instructions adherence to the documented protocols established in Requirement R1 occurred every twelve months during the audit period. Verify assessment or another artifact includes evidence such as annotations or summaries of providing feedback and taking corrective action, as necessary, in accordance with the requirement.(Part 4.2) That the effectiveness of documented communications protocols in Requirement R1 was assessed every twelve months during the audit period.For Emergencies, occurring on the entity’s system, or a sample thereof, verify entity took appropriate corrective actions by reviewing summaries, meeting minutes, or the like, outlining corrective actions taken in response to operating personnel’s non-adherence to documented protocols where that non-adherence was the partial or sole cause of the Emergency.

Note to Auditor:Auditors can use their general knowledge of the entity’s system, discussions with other Regional Entity/NERC personnel, and discussions with entity personnel to gain an awareness of Emergencies resulting potentially from non-adherence to communications protocols. Such Emergency events can then be reviewed during an audit to determine, if the Emergency was indeed attributable to an instance of non-adherence to communications protocols, that corrective action was taken.

The extent of audit procedures applied related to this requirement will vary depending on certain risk factors to the Bulk Electric System. In general, more extensive audit procedures will be applied where risks to the Bulk


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Electric System are determined by the auditor to be higher for non-compliance with this requirement.

Auditor Notes:


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R5. Each Balancing Authority, Reliability Coordinator, and Transmission Operator that issues an oral two-party, person-to-person Operating Instruction during an Emergency, excluding written or oral single-party to multiple-party burst Operating Instructions, shall either:

Confirm the receiver’s response if the repeated information is correct (in accordance with Requirement R6).

Reissue the Operating Instruction if the repeated information is incorrect or if requested by the receiver, or

Take an alternative action if a response is not received or if the Operating Instruction was not understood by the receiver.

M5. Each Reliability Coordinator, Transmission Operator, and Balancing Authority that issued an oral two-party, person-to-person Operating Instruction during an Emergency, excluding oral single-party to multiple-party burst Operating Instructions, shall have evidence that the issuer either: 1) confirmed that the response from the recipient of the Operating Instruction was correct; 2) reissued the Operating Instruction if the repeated information was incorrect or if requested by the receiver; or 3) took an alternative action if a response was not received or if the Operating Instruction was not understood by the receiver. Such evidence could include, but is not limited to, dated and time-stamped voice recordings, or dated and time-stamped transcripts of voice recordings, or dated operator logs in fulfillment of Requirement R5.


Evidence Requestedi:Provide the following evidence, or other evidence to demonstrate compliance. Dated and time-stamped voice recordings or transcripts of such voice recordings or operator logs, as described in M5.



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Review the evidence provided and verify:That for Operating Instructions issued during an Emergency the entity confirmed the receiver’s response if the repeated information was correct (in accordance with Requirement R6), reissued the Operating Instruction if the repeated information was not correct or if requested by the receiver, or took alternative action to issue a new or the same Operating Instruction if the receiver did not respond.

Note to Auditor:Auditors can use their general knowledge of the entity’s system, discussions with other Regional Entity/NERC personnel, and discussions with entity personnel to gain an awareness of Emergencies resulting potentially from non-adherence to Requirement R5. Such Emergency events can then be reviewed during an audit to determine if the evidence indicates the entity complied with Requirement R5 in issuing Operating Instructions during the Emergency.

The extent of audit procedures applied related to this requirement will vary depending on certain risk factors to the Bulk Electric System. In general, more extensive audit procedures will be applied where risks to the Bulk Electric System are determined by the auditor to be higher for non-compliance with this requirement.

Auditor Notes:


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R6. Each Balancing Authority, Distribution Provider, Generator Operator, and Transmission Operator that receives an oral two-party, person-to-person Operating Instruction during an Emergency, excluding written or oral single-party to multiple-party burst Operating Instructions, shall either:

Repeat, not necessarily verbatim, the Operating Instruction and receive confirmation from the issuer that the response was correct, or


M6. Each Balancing Authority, Distribution Provider, Generator Operator, and Transmission Operator that was the recipient of an oral two-party, person-to-person Operating Instruction during an Emergency, excluding oral single-party to multiple-party burst Operating Instructions, shall have evidence to show that the recipient either repeated, not necessarily verbatim, the Operating Instruction and received confirmation from the issuer that the response was correct, or requested that the issuer reissue the Operating Instruction in fulfillment of Requirement R6. Such evidence may include, but is not limited to, dated and time-stamped voice recordings (if the entity has such recordings), dated operator logs, an attestation from the issuer of the Operating Instruction, memos or transcripts.


Evidence Requestedi:Provide the following evidence, or other evidence to demonstrate compliance. Dated operator logs, voice recordings, memos, or transcripts, or other evidence (per M6) describing the entity’s response to Operating Instructions received during an Emergency.



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Review the evidence provided and verify:That for Operating Instructions received during an Emergency, that the entity repeated, not necessarily verbatim, the Operating Instruction and received confirmation from the issuer that the response was correct, or requested that the issuer reissue the Operating Instruction.

Note to Auditor:Auditors can use their general knowledge of the entity’s system, discussions with other Regional Entity/NERC personnel, and discussions with entity personnel to gain an awareness of Emergencies resulting potentially from non-adherence to Requirement R6. Such Emergency events can then be reviewed during an audit to determine if the evidence indicates the entity complied with Requirement R6 for Operating Instructions received during the Emergency.


Auditor Notes:


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R7. Each Balancing Authority, Reliability Coordinator, and Transmission Operator that issues a written or oral single-party to multiple-party burst Operating Instruction during an Emergency shall confirm or verify that the Operating Instruction was received by at least one receiver of the Operating Instruction.

M7. Each Balancing Authority, Reliability Coordinator and Transmission Operator that issued a written or oral single or multiple-party burst Operating Instruction during an Emergency shall provide evidence that the Operating Instruction was received by at least one receiver. Such evidence may include, but is not limited to, dated and time-stamped voice recordings (if the entity has such recordings), dated operator logs, electronic records, memos or transcripts.


Evidence Requestedi:Provide the following evidence, or other evidence to demonstrate compliance. Dated and time-stamped voice recordings, dated operator logs, electronic records, memos, or transcripts, as described in M7, that during the Emergency, the Operating Instruction was received by at least one receiver.



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Review the evidence provided and verify:


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The entity confirmed or verified that the multiple-party burst Operating Instruction was received by at least one receiver of the Operating Instruction.

Note to Auditor:Auditors can use their general knowledge of the entity’s system, discussions with other Regional Entity/NERC personnel, and discussions with entity personnel to gain an awareness of Emergencies resulting potentially from non-adherence to Requirement R7. Such Emergency events can then be reviewed during an audit to determine if the evidence indicates the entity complied with Requirement R7 when issuing written or oral burst Operating Instructions during the Emergency.


Auditor Notes:


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Additional Information :

Reliability Standard

The full text of COM-002-4 may be found on the NERC Web Site (www.nerc.com) under “Program Areas & Departments”, “Reliability Standards.”

In addition to the Reliability Standard, there is an applicable Implementation Plan available on the NERC Web Site.

In addition to the Reliability Standard, there is background information available on the NERC Web Site.

Capitalized terms in the Reliability Standard refer to terms in the NERC Glossary, which may be found on the NERC Web Site.

Sampling Methodology Sampling is essential for auditing compliance with NERC Reliability Standards since it is not always possibleor practical to test 100% of either the equipment, documentation, or both, associated with the full suite of enforceable standards. The Sampling Methodology Guidelines and Criteria (see NERC website), or sample guidelines, provided by the Electric Reliability Organization help to establish a minimum sample set for monitoring and enforcement uses in audits of NERC Reliability Standards.

Regulatory Language

FERC approved COM-002-4 on April 16, 2015. Communications Reliability Standards, Order No. 808, 151 FERC ¶ 61,039 (2015).

In Order No. 808, FERC noted that the revised COM-002-4 and COM—001-2 Reliability Standards will enhance reliability by, among other things, requiring adoption of predefined communication protocols, annual assessment of those protocols and operating personnel’s adherence thereto, training on the protocols, and use of three-part communications..

P 2: Reliability Standard COM-002-4 requires applicable entities to develop communication protocols with certain minimum requirements, including use of three-part communication when issuing Operating

Instructions. Reliability Standard COM-002-4 also sets out certain communications training requirements for all issuers and recipients of Operating Instructions, and establishes a flexible enforcement approach for failure to use three-part communication during non-emergencies and a “zero-tolerance,” i.e., without exception, enforcement approach for failure to use three-part communication during an emergency.


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http://www.nerc.com/FilingsOrders/us/FERCOrdersRules/Order%20No.%20808%20Approving%20Reliability%20Standards%20COM-001-2%20and%20COM-002-4.pdf

http://www.nerc.com/FilingsOrders/us/FERCOrdersRules/Order%20No.%20808%20Approving%20Reliability%20Standards%20COM-001-2%20and%20COM-002-4.pdf


P 18: Both Requirement R5 and R6 include the clarification that the requirement does not apply to single-party to multiple-party “burst” Operating Instructions. As noted above, NERC explains that Requirements R5 and R6 require use of three-part communication during an Emergency without exception, because “use of three-part communication is critically important if an Emergency condition already exists, as further action or inaction could increase the harmful effects to the Bulk Electric System.” NERC further explains, however, that applicable entities are expected to use three-part communications at all times when issuing and receiving Operating Instructions.

Selected Glossary TermsThe following Glossary terms are provided for convenience only. Please refer to the NERC web site for the current enforceable terms.

Emergency – Any abnormal system condition that requires automatic or immediate manual action to prevent or limit the failure of transmission facilities or generation supply that could adversely affect the reliability of the Bulk Electric System.

Operating Instruction – A command by operating personnel responsible for the Real-time operation of the interconnected Bulk Electric System to change or preserve the state, status, output, or input of an Element of the Bulk Electric System or Facility of the Bulk Electric System. (A discussion of general information and of potential options or alternatives to resolve Bulk Electric System operating concerns is not a command and is not considered an Operating Instruction.)


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Revision History for RSAW

Version Date Reviewers Revision Description

1 10/2013 NERC Compliance, Standards

New Document

2 1/2/2014 NERC Compliance, Standards

Revised to reflect revisions to the draft Reliability Standard language.

3 2/19/2016NERC Compliance Assurance, RSAW Task Force

Revised for consistency with the final approved Standard.


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i Items in the Evidence Requested section are suggested evidence that may, but will not necessarily, demonstrate compliance. These items are not mandatory and other forms and types of evidence may be submitted at the entity’s discretion.

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